ML18355A824

LLC Response to NRC Request for Additional Information No. 442 (Erai No. 9479) on the NuScale Design Certification Application

ML18355A824
Person / Time
Site:	NuScale
Issue date:	12/21/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18355A823	List: ML18355A824
References
AF-1218-63937, RAIO-1218-63936
Download: ML18355A824 (10)

Text

RAIO-1218-63936 December 21, 2018 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Response to NRC Request for Additional Information No.

442 (eRAI No. 9479) on the NuScale Design Certification Application

REFERENCE:

U.S. Nuclear Regulatory Commission, "Request for Additional Information No.

442 (eRAI No. 9479)," dated April 30, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's response to the following RAI Question from NRC eRAI No. 9479:

15.06.05-5 is the proprietary version of the NuScale Response to NRC RAI No. 442 (eRAI No.

9479). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavit (Enclosure 3) supports this request. Enclosure 2 is the nonproprietary version of the NuScale response.

This letter and the enclosed responses make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Paul Infanger at 541-452-7351 or at pinfanger@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Rani Franovich, NRC, OWFN-8G9A NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1218-63936 : NuScale Response to NRC Request for Additional Information eRAI No. 9479, proprietary : NuScale Response to NRC Request for Additional Information eRAI No. 9479, nonproprietary : Affidavit of Zackary W. Rad, AF-1218-63937 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1218-63936 :

NuScale Response to NRC Request for Additional Information eRAI No. 9479, proprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1218-63936 :

NuScale Response to NRC Request for Additional Information eRAI No. 9479, nonproprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9479 Date of RAI Issue: 04/30/2018 NRC Question No.: 15.06.05-5 Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criterion (GDC) 35, "Emergency Core Cooling," requires that a system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. DSRS Section 15.6.5 provides guidance for complying with GDC 35. It requires that evaluation models meet the requirements of 10 CFR 50.46, which states that the evaluation model must include sufficient supporting justification to show that the analytical technique realistically describes the behavior of the reactor system during a loss-of-coolant accident.

Section 5.3.2 of the Long-Term Cooling Methodology (LTC) technical report, TR-0916-51299-P, Rev. 0, a technical report referenced in the DCD Chapter 15 analyses, describes input model changes where it was necessary to isolate heat transfer to the secondary side (SG tubes and DHRS) in order to facilitate code convergence. The applicant admits that this modeling is not consistent with biasing for needed maximum cooldown, and indicated that the effect was negligible based on sensitivity calculations. Based on review of EC-A010-4270 (a calculation supporting the DCD Chapter 15 analyses), staff noted that DHRS was being isolated upon ECCS actuation but did not find any sensitivity analysisor discussions or discussions to justify these changes as being appropriate for the maximum cooldown LTC cases.

Please revise the methodology to include DHRS cooling or provide an analysis justification for DHRS isolation that is appropriate for post-LOCA long-term cooling, and provide markups of any necessary changes to the technical report.

NuScale Nonproprietary

NuScale Response:

The NPM LTC analyses have been revised based on the updated NRELAP5 model, analysis scope and boundary condition assumptions.

As part of the revised LTC analyses, a DHRS cooling sensitivity study was performed for the minimum temperature case (previously referred to as the maximum cooldown rate case). The DHRS sensitivity study demonstrated that the operation of DHRS provides a slightly lower core inlet temperature as a result of the additional DHRS cooling (Figure 1). Therefore, all of the minimum temperature cases evaluated as part of the revised LTC analyses consider operation of DHRS. DHRS operation is considered for the entire duration of the transient analyses to ensure the effects of DHRS cooling are included in the calculation of the minimum core inlet temperature.

The LTC technical report was revised to incorporate updated LTC analyses results that consider cases with and without DHRS operation depending on biasing requirements derived from sensitivity studies as indicated in the response to RAI 9516, question 15-26, submitted in NuScale letter RAIO-1218-63931, dated December 21, 2018. For those cases that consider DHRS operation, DHRS cooling is enabled for the entire duration of the transient analyses.

NuScale Nonproprietary

((2(a),(c) Figure 1: Minimum temperature injection line break: core inlet temperature Impact on DCA: There are no impacts to the DCA as a result of this response. NuScale Nonproprietary

RAIO-1218-63936 : Affidavit of Zackary W. Rad, AF-1218-63937 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows:

1. I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale.

2. I am knowledgeable of the criteria and procedures used by NuScale in designating information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following:

a. The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale.

b. The information requested to be withheld consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit.

c. Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

d. The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale.

e. The information requested to be withheld consists of patentable ideas.

3. Public disclosure of the information sought to be withheld is likely to cause substantial harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the method by which NuScale develops its long term cooling analysis.

NuScale has performed significant research and evaluation to develop a basis for this method and has invested significant resources, including the expenditure of a considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a NuScale plant and, therefore, has substantial value to NuScale. If the information were disclosed to the public, NuScale's competitors would have access to the information without purchasing the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise its competitive advantage to seek an adequate return on its investment. AF-1218-63937

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 442, eRAI 9479. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information. The information considered by NuScale to be proprietary is identified within double braces, "(( }}" in the document.

5. The basis for proposing that the information be withheld is that NuScale treats the information as a trade secret, privileged, or as confidential commercial or financial information. NuScale relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC § 552(b)(4), as well as exemptions applicable to the NRC under 10 CFR §§ 2.390(a)(4) and 9.17(a)(4).

6. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld is owned and has been held in confidence by NuScale.

b. The information is of a sort customarily held in confidence by NuScale and, to the best of my knowledge and belief, consistently has been held in confidence by NuScale.

The procedure for approval of external release of such information typically requires review by the staff manager, project manager, chief technology officer or other equivalent authority, or the manager of the cognizant marketing function (or his delegate), for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside NuScale are limited to regulatory bodies, customers and potential customers and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality.

c. The information is being transmitted to and received by the NRC in confidence.

d. No public disclosure of the information has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence.

e. Public disclosure of the information is likely to cause substantial harm to the competitive position of NuScale, taking into account the value of the information to NuScale, the amount of effort and money expended by NuScale in developing the information, and the difficulty others would have in acquiring or duplicating the information. The information sought to be withheld is part of NuScale's technology that provides NuScale with a competitive advantage over other firms in the industry.

NuScale has invested significant human and financial capital in developing this technology and NuScale believes it would be difficult for others to duplicate the technology without access to the information sought to be withheld. I declare under penalty of perjury that the foregoing is true and correct. Executed on December 21, 2018. Zackary W. Rad AF-1218-63937}}